Special Topics in Environmental Management

Q&A: SPCC Plans

Q: What should I do if an EPA or engineer’s inspection finds deficiencies in loading or unloading containments that should be addressed by the SPCC Plan?

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A: A common deficiency at petroleum distributor storage facilities is inadequate or deficient truck loading or unloading containment. This deficiency may be identified by an EPA inspection but more frequently, it is recognized by the SPCC engineer. This condition must be addressed under the federal SPCC rules quickly by completing a written review and evaluation of the existing SPCC plan. Within the next six months, the SPCC plan must be amended. After that, the required upgrades must be accomplished within the following six months. In addition, the operator typically needs to be advised by the SPCC engineer on how to correct this deficiency, for example, by designing and constructing such containment and working with the operator to assure these upgrades are implemented within the allowed one year.

Clearly it is beneficial to identify and address such deficiencies before an EPA inspection that will almost certainly lead to costly penalties, imposed environmental projects, legal and engineering fees, other costs and related disruptions. All of these costs will be in addition to the upgrades. A negative EPA inspection can also lead to subsequent EPA scrutiny of the operator’s compliance with other environmental regulations.

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